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U.S. BANCORP v. COMMISSIONER

Docket No. 27342-96.

111 T.C. 231 (1998)

U.S. BANCORP AND ITS CONSOLIDATED SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 21, 1998.

Attorney(s) appearing for the Case

Richard A. Edwards and David W. Brown, for petitioner.

William P. Boulet, Jr., and Virginia L. Hamilton, for respondent.

OPINION

BEGHE, Judge:

This matter is before the Court on the parties' motions for partial summary judgment filed under Rule 121.2 Petitioner's principal office was located in Portland, Oregon, when it filed the petition.

The sole issue for decision is whether the charge incurred by a lessee in terminating a lease of a mainframe computer and simultaneously initiating a new lease of a more powerful mainframe computer...

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